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“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

Reassessment proceedings are invalid if initiated based on documents already available on record without fresh tangible material, and if the sanction under section 151 is accorded mechanically, indicating non-application of mind.

M/s Sahara India (Farms) v. CIT & Anr.
300 ITR 403 · 2008 · Supreme Court
268
citing judgments

The requirement of statutory prior approval by a high-ranking authority, even if administrative, serves as an in-built protection against arbitrary exercise of power by the Assessing Officer. While such approval need not record elaborate reasoning, the approving authority has a heavy duty to ensure it is not an empty ritual, fulfilling its purpose of supervisory control.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT
367 ITR 112 · 2014 · High Court
225
citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Judgments citing reasons recorded

Jain Textile Industries, Gurgaon vs. Assistant Commissioner of Income-Tax, Circle-1(1), Gurgaon

In the result, Appeal of the Assessee is dismissed as devoid of

ITA 932/DEL/2025[2014-15]Status: DisposedITAT Delhi24 Oct 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Jain Textile Industries, V Assistant Commissioner Of 38, Milestone, Behrampur S Income Tax, Circle-1(1) Road, Village Khandsa, Hsiiddc Building, 4Th Floor, Gurgaon, Haryana Udyog Vihar, Phase-V, Gurgaon Pan: Aabfj8405F Appellant Respondent Assessee By Sh. Bhupender Jit Kumar, Adv, Sh. Nikhil Sharma, Adv & Sh. Tushar Kalra, Adv Revenue By Sh. Dheeraj Kumar Jain, Sr. Dr Date Of Hearing 03/09/2025 Date Of Pronouncement 24/10/2025

Section 143(3)Section 144Section 147Section 251(1)(a)

vide acknowledgement no. 345444901270421. This was intimated vide response dated 27.04.2021 duly uploaded on the e-fling portal. Thereafter, the Appellant requested for providing reasons recorded for reopening the assessment. The reasons in the form of letter bearing DIN & Letter No. ITBA/ AST/ F/17/2021-22/1035150715(1) dated 27.08.2021 were provided

Agrawala Finserve Pvt Ltd, Delhi vs. ITO Ward-1(4), Delhi

In the result, appeal of the assessee is allowed

ITA 3503/DEL/2025[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: SHRI VIKAS AWASTHY (Judicial Member)

For Appellant: S/Shri Mukesh Kumar Jain & Atul DhamaFor Respondent: Ms. Sudha Gupta, Sr.DR
Section 133(6)Section 143(3)Section 147Section 148

assessment order is at page no.73 of the paper book. Thereafter, notice u/s.148 of the Act was issued to the assessee on 26.03.2019. The reasons recorded for reopening are at pages 6 to 8 of the paper book. The ld. AR of the assessee submitted that a bare perusal ... which, assessment has been reopened has already been examined by the AO in scrutiny assessment proceedings. The ld. AR pointed that the AO in reasons recorded for reopening has referred to four names i.e. M/s. Sunrise Dealmark Ltd., M/s. Shyama Dealtrade P. Ltd., M/s. Midpoint Traders

Sri Prem Properties Private Limited, Gurgaon vs. ACIT, Circle-24(1), New Delhi, Delhi

In the result, appeal filed by the assessee is allowed

ITA 957/DEL/2024[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Sri Prem Properties Private Limited, Vs. Acit, Circle 24 (1), A – 99, Bajghera Chowk, Delhi. New Palam Vihar, Gurgaon – 122 017 (Haryana). (Pan :Aaacs2554E) (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate Shri Skasham Agarwal, Ca Shri Deepesh Garg, Advocate Revenue By : Ms. Kirti Sankratyayan, Cit Dr Date Of Hearing : 01.09.2025 Date Of Order : 24.10.2025 Order Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income-Tax (Appeals)-23, New Delhi [For Short ‘Ld. Cit (A)]Dated 04.01.2024 For Assessment Year 2012-13. 2. Brief Facts Of The Case Are, Assessee Filed Its Original Return Of Income On 30.09.2012 Declaring An Income Of Rs.2,15,340/-. The Case Of The Assessee Was Selected For Scrutiny For The Year Under Consideration.

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Ms. Kirti Sankratyayan, CIT DR
Section 132Section 147Section 148

ground which is against assumption of jurisdiction under section 147. He referred to pages 32 to 34 of the paper book which are the reasons recorded. He further submitted that validity of reopening is to be judged with reference to Reason recorded alone and this regard, he relied ... submitted that Information of forfeiture of earnest money is there on the face of profit Loss Account and there is nothing more in the reason recorded except that similar write off has been made by another company, M/s Brisk Infra. He brought to our notice page 25 of the paper

Surinder Kumar Chhabra, Gurgaon vs. Circle 4(1), Gurgaon

In the result, appeal of the assessee is allowed for statistical purposes

ITA 4776/DEL/2024[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 143Section 147Section 148Section 69C

declaring a total income of Rs. 5,38,58,140/-. Upon the assessee's request, a copy of the reasons recorded for re-assessment u/s 147 of the Act were provided to the assessee vide letter dated 14.05.2019. During the course of assessment proceedings, according to the AO, the genuineness

Deputy Commissioner of Income Tax, Delhi vs. Scan Holdings Private Limited, Delhi

Appeal is dismissed

ITA 3753/DEL/2024[2008-09]Status: DisposedITAT Delhi24 Oct 2025AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2008-09] Dcit, M/S Scan Holdings (P) Ltd., Circle-22(2), Room No.- 225E F-4, Shopping Complex, C.R. Building, I.P. Estate, Vs A-Block, Meera Bagh, New Delhi-110002 Delhi-110087. Pan- Pan- Aabcs0852N Revenue Assessee C.O. No.- 38/Del/2025 Arising Out Of Ita No.3753/Del/2024 [Assessment Year: 2008-09] M/S Scan Holdings (P) Ltd., Dcit, F-4, Shopping Complex, Circle-22(2), Room No.- 225E A-Block, Meera Bagh, Vs C.R. Building, I.P. Estate, Delhi-110087. New Delhi-110002 Pan- Aabcs0852N Assessee Revenue

Section 143(2)Section 143(3)Section 148Section 14A

filed on 28.09.2008 should be treated as its return filed against notice u/s 148 of the Act. The assessee company sought copy of the reasons recorded which was supplied to the assesse company by the AO on 27.04.2015 and at the same time the assessee company was issued notice ... circumstances of the case, the Ld. CIT(A) has erred in deleting the addition in respect of Rs.21971126/- being commission received.” 5.1 The reasons recorded by the AO for reopening the assessment in this case, on this issue along with the finding of the AO in the assessment order

DCIT, Central Circle-14, Delhi vs. Parveen Aggarwal, Gurgaon

Accordingly the same are hereby upheld. Grounds of appeal Nos. 1 & 2 raised by the Revenue are dismissed

ITA 197/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2012-13] Parveen Aggarwal, Vs Acit, Ma-1/7, 3D, Garden Central Circle-14, Estate, M.G.Road, Gurgaon New Delhi Haryana-122002. Pan-Aahpa0660R Appellant Respondent [Assessment Year : 2012-13] Dcit, Vs Parveen Aggarwal, Central Circle-14, Ma-1/7, 3D, Garden New Delhi Estate, M.G.Road, Gurgaon, Haryana-122002. Pan-Aahpa0660R Appellant Respondent Assessee By Shri K.Sampath, Adv. & Shri V.Rajkumar, Adv. Revenue By Ms. Pooja Swaroop, Cit Dr Date Of Hearing 29.07.2025 Date Of Pronouncement 24.10.2025 Order Per Manish Agarwal, Am : The Captioned Cross-Appeals Are Filed By The Assessee & The Revenue Against The Order Of Ld. Commissioner Of Income Tax (A)- 27, New Delhi [“Ld. Cit(A)”] Dated 28.11.2022 In Appeal No. Cit(A), Delhi-27/10482/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dt. 31.12.2019 Passed U/S 143(3) R.W.S. 147 Of The Act Pertaining To Assessment Year 2012-13. Ita Nos.178 & 197/Del/2023

Section 143(3)Section 147Section 148Section 250

make any further inquiries/investigations in this regard and accepted the transactions as valid and disclosed transactions. 7. Ld. AR further submits that in the reasons recorded, AO observed that bank account was never examined in the course of assessment proceedings which fact is not correct as the said account ... both the parties and perused the material available on record. From the perusal of the orders of lower authorities, we find that in the reasons recorded, AO has clearly observed that entries contained in the bank account were not examined during the course of assessment proceedings completed u/s 153C

Parveen Aggarwal, Gurgaon vs. ACIT Central Circle-14, New Delhi

Accordingly the same are hereby upheld. Grounds of appeal Nos. 1 & 2 raised by the Revenue are dismissed

ITA 178/DEL/2023[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2012-13] Parveen Aggarwal, Vs Acit, Ma-1/7, 3D, Garden Central Circle-14, Estate, M.G.Road, Gurgaon New Delhi Haryana-122002. Pan-Aahpa0660R Appellant Respondent [Assessment Year : 2012-13] Dcit, Vs Parveen Aggarwal, Central Circle-14, Ma-1/7, 3D, Garden New Delhi Estate, M.G.Road, Gurgaon, Haryana-122002. Pan-Aahpa0660R Appellant Respondent Assessee By Shri K.Sampath, Adv. & Shri V.Rajkumar, Adv. Revenue By Ms. Pooja Swaroop, Cit Dr Date Of Hearing 29.07.2025 Date Of Pronouncement 24.10.2025 Order Per Manish Agarwal, Am : The Captioned Cross-Appeals Are Filed By The Assessee & The Revenue Against The Order Of Ld. Commissioner Of Income Tax (A)- 27, New Delhi [“Ld. Cit(A)”] Dated 28.11.2022 In Appeal No. Cit(A), Delhi-27/10482/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dt. 31.12.2019 Passed U/S 143(3) R.W.S. 147 Of The Act Pertaining To Assessment Year 2012-13. Ita Nos.178 & 197/Del/2023

Section 143(3)Section 147Section 148Section 250

make any further inquiries/investigations in this regard and accepted the transactions as valid and disclosed transactions. 7. Ld. AR further submits that in the reasons recorded, AO observed that bank account was never examined in the course of assessment proceedings which fact is not correct as the said account ... both the parties and perused the material available on record. From the perusal of the orders of lower authorities, we find that in the reasons recorded, AO has clearly observed that entries contained in the bank account were not examined during the course of assessment proceedings completed u/s 153C

Tapas Kumar Sarkar, Barasat, North Twenty Four Parganas vs. I.T.O., Ward - 50(1), Kolkata

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 1873/KOL/2025[2013-2014]Status: DisposedITAT Kolkata23 Oct 2025AY 2013-2014

Bench: Shri Udayan Das Gupta & Shri Rakesh Mishra

Section 147Section 194Section 194CSection 194JSection 250Section 40

notices u/s 143(2) and 142(1) of the Act were issued to the assessee and he was also provided with a copy of reasons recorded by the Assessing Officer (hereinafter referred to as Ld. 'AO') for initiation of proceedings u/s 147 of the Act. After considering the reply submitted

Tapas Kumar Sarkar, Barasat, North Twenty Four Parganas vs. I.T.O., Ward - 50(1), Kolkata

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 1872/KOL/2025[2012-2013]Status: DisposedITAT Kolkata23 Oct 2025AY 2012-2013

Bench: Shri Udayan Das Gupta & Shri Rakesh Mishra

Section 147Section 194Section 194CSection 194JSection 250Section 40

notices u/s 143(2) and 142(1) of the Act were issued to the assessee and he was also provided with a copy of reasons recorded by the Assessing Officer (hereinafter referred to as Ld. 'AO') for initiation of proceedings u/s 147 of the Act. After considering the reply submitted

Balachandra Builders Pvt. Ltd., Chennai vs. DCIT, Corp. Circle-1(2), Chennai

In the result, appeal of the assessee is allowed

ITA 989/CHNY/2025[2010-11]Status: DisposedITAT Chennai21 Oct 2025AY 2010-11

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 989/Chny/2025 िनधा"रण वष"/Assessment Year : 2010-11 V. Balchandra Builders Private Limited, Deputy Commissioner Of No.10 Venkataratnam Nagar, Adyar, Income Tax, Chennai- 600 020. Corporate Circle 1(2), Chennai. [Pan: Aaacb6727A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.N.Arjun Raj, Advocate, : ""यथ" क" ओर से /Respondent By Ms.R.Anitha, Addl.Cit : सुनवाई क" तार"ख/Date Of Hearing 28.07.2025 : घोषणा क" तार"ख /Date Of Pronouncement 21.10.2025

Section 143(2)Section 143(3)Section 147Section 148Section 80I

passed on 28.03.2013. Balachandra Builders Pvt Ltd :: 3 :: The Ld.Counsel further referred the paper book wherein at page 48 reasons recorded for reopening of assessment dated 19.09.2015 is placed. Following reasons are recorded by the AO. "On verification of scrutiny records, the assessee had claimed the LTCG ... assessment u/s 148 of the Act. 6. We have heard the rival submissions and perused the record also assessee’s paper book for reasons recorded u/s. 147 of the Act. In reasons recorded, the opening sentence is that "On verification of scrutiny records, the assessee had claimed the LTCG

Mr. Arpanbhai Virambhai Desai, Gandhinagar vs. The Pr. CIT, Ahmedabad-3, Ahmedabad

In the result, all four appeals filed by the assessee are\nallowed in above terms

ITA 759/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2015-16
For Appellant: \nShri D K Parikh, ARFor Respondent: \nShri Sher Singh, CIT.DR
Section 12Section 147Section 263

reopening of the assessment under Section 147 of the\nAct 1961 is well-settled.\n(i) The Court should be guided by the reasons recorded for the reassessment and not\nby the reasons or explanation given by the Assessing Officer at a later stage in respect\nof the notice ... purpose of the Act, the validity of the assumption of jurisdiction\nunder Section 147 can be tested only by reference to the reasons recorded\nunder Section 148(2) of the Act and the Assessing Officer is not authorized to refer to\nany other reason even if it can be otherwise

Mr. Arpanbhai Virambhai Desai, Gandhinagar vs. Pr.CIT, Ahmedabad-3, Ahmedabad

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 758/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2014-15

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

regards the reopening of the assessment under Section 147 of the Act 1961 is well-settled. (i) The Court should be guided by the reasons recorded for the reassessment and not by the reasons or explanation given by the Assessing Officer at a later stage in respect of the notice ... purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorized to refer to any other reason even if it can be otherwise

Mr. Arpanbhai Virambhai Desai, Gandhinagar vs. The ITO, Ward-1, Int.Tax., Ahmedabad

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 339/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

regards the reopening of the assessment under Section 147 of the Act 1961 is well-settled. (i) The Court should be guided by the reasons recorded for the reassessment and not by the reasons or explanation given by the Assessing Officer at a later stage in respect of the notice ... purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorized to refer to any other reason even if it can be otherwise

Mr. Arpanbhai Virambhai Desai, Gandhinagar vs. The ITO, Ward-1, Int.Tax., Ahmedabad

In the result, all four appeals filed by the assessee are allowed in above terms

ITA 338/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri D K Parikh, ARFor Respondent: Shri Sher Singh, CIT.DR
Section 12Section 147Section 263

regards the reopening of the assessment under Section 147 of the Act 1961 is well-settled. (i) The Court should be guided by the reasons recorded for the reassessment and not by the reasons or explanation given by the Assessing Officer at a later stage in respect of the notice ... purpose of the Act, the validity of the assumption of jurisdiction under Section 147 can be tested only by reference to the reasons recorded under Section 148(2) of the Act and the Assessing Officer is not authorized to refer to any other reason even if it can be otherwise

M/S Sapphire Fintech Private Limited, Mumbai vs. DCIT-3(3)(1), Mumbai

In the result, the appeal by the assessee for the

ITA 593/MUM/2023[2010-11]Status: DisposedITAT Mumbai17 Oct 2025AY 2010-11
For Appellant: Shri Mahavir JainFor Respondent: Shri Swapnil Choudhary, Sr. AR
Section 133ASection 147Section 148Section 250Section 68

unsecured loan, notice under\nsection 148 of the Act was issued on 24/03/2014 and proceedings under\nsection 147 of the Act were initiated. The reasons recorded by the AO for\nreopening the assessment are reproduced as follows:\n\"This office received information from the office of the DGIT(inv), Mumbai

M/S Sapphire Fintech Private Limited, Mumbai vs. DCIT -3(3)(1), Mumbai

In the result, the appeal by the assessee for the

ITA 592/MUM/2023[2007-2008]Status: DisposedITAT Mumbai17 Oct 2025AY 2007-2008
For Appellant: Shri Mahavir JainFor Respondent: Shri Swapnil Choudhary, Sr. AR
Section 133ASection 147Section 148Section 250Section 68

unsecured loan, notice under\nsection 148 of the Act was issued on 24/03/2014 and proceedings under\nsection 147 of the Act were initiated. The reasons recorded by the AO for\nreopening the assessment are reproduced as follows:\n\"This office received information from the office of the DGIT(inv), Mumbai

Raheja Developers Limited, New Delhi vs. DCIT, Central Circle 19, New Delhi

ITA 2284/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

28/08/2018 which is after 46 days of providing reasons for reopening. Thereafter the Assessee filed objectionafter 124 days from the date of supplying the reasons recorded for reopening. The Assessee deliberately filed the objection at the fag end of the assessment proceedings. The said objection has been decided ... bonfide belief that the Assessee has no objection on reopening of the case. However, Assessee filed objections after 124 days from the receipt of reasons recorded for reopening of the case. The Assessee deliberately filed the objection after expiry of 124 days at the end of the assessment proceedings which

Raheja Developers Limited, New Delhi vs. ACIT, Central Circle 19, Delhi

ITA 2283/DEL/2023[2011-12]Status: DisposedITAT Delhi17 Oct 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No.2283/Del/2023 (A.Y 2011-12) Raheja Developers Limited Vs Acit W4D-204/5, Keshav Kunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent I.T.A. No.2284/Del/2023 (A.Y 2012-13) Raheja Developers Limited Vs Acit W4D-204/5, Keshavkunj, Central Circle-19 Cariappa Marg, Sainik Farms, New Delhi New Delhi, Pan: Aaacr0468E Appellant Respondent Assessee By Sh. Neeraj Jain, Ca& Sh. P. K. Mishra, Ca Revenue By Ms.Pooja Swaroop, Cit (Dr) Date Of Hearing 24/07/2025 Date Of Pronouncement 17/10/2025

Section 143(3)Section 147Section 148Section 14ASection 68

28/08/2018 which is after 46 days of providing reasons for reopening. Thereafter the Assessee filed objectionafter 124 days from the date of supplying the reasons recorded for reopening. The Assessee deliberately filed the objection at the fag end of the assessment proceedings. The said objection has been decided ... bonfide belief that the Assessee has no objection on reopening of the case. However, Assessee filed objections after 124 days from the receipt of reasons recorded for reopening of the case. The Assessee deliberately filed the objection after expiry of 124 days at the end of the assessment proceedings which

Sollfege Electronics Private Limited (Presently Known As Sollfege Electronics Limited), Kolkata vs. ITO, Ward 8(2), Kolkata

In the result, appeal of the assessee is allowed

ITA 1012/KOL/2025[2018-2019]Status: DisposedITAT Kolkata16 Oct 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.1012/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2018-2019) Sollfege Electronics Private Vs Ito Ward 8(2), Limited P-7, Chowringhee Square, (Presently Known As Sollfege Kolkata-700069, West Bengal Electronics Limited) 3, Pretoria Street, 2Nd Floor, Chandrakunj Building, Kolkata-700071, West Bengal Pan No. :Aaecd4463B (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri Soumitra Choudhury & Shri Pranabesh Sarkar, Advocates रधजस्व की ओर से /Revenue By : Shri S.B.Chakraborthy, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 27/08/2025 घोषणा की तारीख/Date Of Pronouncement : 16/10/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Assessee Against The Order Dated 22.03.2025, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2018-2019. 2. At The Time Of Hearing, Ld.Counsel For The Assessee Pressed The Grounds No.8, 9, 10 & 11, Which Are Raised By The Assessee To Challenge The Confirmation Of Addition By The Ld. Cit(A) Of Rs.60.00 Lakhs Made By The Assessing Officer U/S.68 Of The Act As Unexplained Cash Credit. 3. Facts In Brief Are That The Assessee Is Engaged In The Business Of Trading Of Electronics Audio, Video Etc. The Assessee Filed Its Return Of Income U/S.139(1) Of The Act On 06.10.2018 Declaring Total Income At Rs.95,23,889/-. The Notice U/S.148A(B) Of The Act Was Issued By The Assessing

For Appellant: Shri Soumitra Choudhury & ShriFor Respondent: Shri S.B.Chakraborthy, Sr.DR
Section 139(1)Section 148Section 148ASection 68

given facts and circumstances, were hold that there is no infirmity in the order of the Ld.CIT-A. " 7 7. For the reasons recorded above, no question of law muchless substantial questions arises in this appeal. It stands meritless and accordingly dismissed. 7. Accordingly, we respectfully following the ratio laid

DCIT, CC-2(3), Kolkata, Aayakar Bhawan Poorva vs. Maxcab Industries Pvt. Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2590/KOL/2024[2021-22]Status: DisposedITAT Kolkata16 Oct 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Dcit, Central Circle-2(3), Maxcab Industries Pvt. Ltd. 4Th Floor, 110 Shantipally, 67/C, Balaram Dey Street, E.M. Bypass, Vs. West Bengal-700006 West Bengal-700107 (Appellant) (Respondent) Pan No. Aancm1997Q Assessee By : Shri Soumitra Choudhury & Ms. Nandini Surekh, Shri Pranabesh Sarkar, Ars Revenue By : Praveen Kishore, Dr Date Of Hearing: 04.09.2025 Date Of Pronouncement: 16.10.2025

For Appellant: Shri Soumitra Choudhury &For Respondent: Praveen Kishore, DR
Section 131Section 132(1)Section 133(6)Section 133ASection 143(1)Section 68

cash deposited in the bank account of the assessee, as wrongly alleged in the recorded reasons. It is thus noted that the reasons recorded prior to reopening proceeded on incorrect assumption of facts and thus ex-facie was was untenable. We further find, that the lender had sufficient own funds